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Take advantage of our free expert resources, written by the experts at LCN Legal, based on their practical experience of working with multinational groups and their advisers across the globe. If you are interested in these areas, you may wish to bookmark this page to check back regularly for new information.

Intra-group transfers at market value or book value

Paul Sutton

This article is taken from the second postcard in our series of cards on group reorganisations, and looks at the price at which assets can be transferred intra-group. Links to the other postcards in the series can be found at the end of this article. This legal issue arises on an ‘upwards’ or ‘sideways’ transfer….

Group Reorganisations

Top 5 Eurobond Myths

Paul Sutton

Top 5 Eurobond Myths The so-called “Quoted Eurobond Exemption” remains an effective way of dealing with UK withholding tax on interest. It is potentially available where the borrower is a UK tax resident company, and the lender is foreign resident. In many ways, the term “Eurobond” is misleading, and it can give rise to a…

Group Reorganisations

How to Use the Solvency Statement Capital Reduction Procedure in UK Group Reorganisations

Paul Sutton

The so-called “solvency statement procedure” is a very straightforward way of creating distributable reserves and enabling assets to be returned to shareholders. This article gives a brief overview of how and when it can be used. 1. What are your objectives? The starting point is to be clear about what you are trying to achieve…

Group Reorganisations

Does the plan work for everyone?

Paul Sutton

LCN Legal has just launched its ‘family photos’ postcard campaign to help finance and tax professionals understand key legal issues affecting group reorganisations. The first postcard deals with the issue of corporate benefit, and is shown below. Thanks to Word of Mouth Communication for the concept and the design. Links to the other postcards in the…

Group Reorganisations

How to Put in Place Effective Intercompany Agreements for Transfer Pricing

Paul Sutton

IMPORTANT NOTE: This article was first published in the Tax Journal on 4 October 2013. Since then, the content has been substantially updated and revised and now forms part of our Free Briefing on How to Create Effective Intercompany Agreements for Transfer Pricing. This Briefing takes into account the 2017 edition of the OECD’s Transfer…

Intercompany Agreements

When is Backdating OK?

Paul Sutton

This is one of the most common issues which comes up in the context of group reorganisations or intercompany agreements. Although it may have been intended to put in place a new arrangement by a particular date – often a year end – that date may now have passed. The question is: can the documents…

Group Reorganisations

Intercompany Agreements

Market value vs Book value: invalidity risks on intra-group transfers

Paul Sutton

Market value vs Book value: invalidity risks on intra-group transfers Group reorganisations often involve the transfer of assets from one company to another. The assets may be tangible or intangible assets, or they may be a debt receivable which is owed by another group company. One of the key issues from a UK company law…

Group Reorganisations

LCN Legal presents training session on Corporate Simplification

Paul Sutton

Paul Sutton, Partner at law firm LCN Legal, has presented a training session for accountants on corporate simplification (also known as ‘legal entity reduction‘). The session focussed on the drivers for corporate simplification projects, as well as key lessons learned from managing similar projects.

Group Reorganisations